ING and the use of customer data
Various Dutch media have reported on a pilot that ING NL plans to launch this year with a small number of customers. Leading up to this pilot, ING is exploring if customers would be interested in receiving tailored discounts from third parties in line with their spending behaviour. In doing so, ING will of course adhere to all privacy requirements. In addition, the pilot is on an opt-in basis, which means that customers must give their explicit consent for their payment details to be analysed. Moreover, ING particularly wants to emphasise that customer data will under no circumstances be sold to third parties.
Millions of customers choose to bank with ING, and therefore use their ING accounts to transfer money and make payments. It goes without saying that these transactions are meticulously recorded; after all, it is in your best interests that transactions are processed correctly, and that they can be easily found in your transaction history, either through Mijn ING (internet banking), the mobile banking app or your printed statements. Apart from the transactions, ING also records personal data and, if you gave permission via cookies, your browsing behaviour on the ING website. This means you don’t have to submit your preferences every time you visit us. It also makes it possible for us to give you tailored information and special offers. For example, information about ‘savings or making down payments on your mortgage’ can be shared with customers who actually have a mortgage, and 15-year old customers will not receive offers regarding pensions.
Recent technological developments allow for the possibility to pool large amounts of data and make calculations based on this data that, until recently, would have required too much time. This development is commonly known as ‘Big Data’. These new technologies have multiple uses, such as in helping to prevent fraud. Imagine if someone uses a debit card to make a payment in location ‘A’, while shortly after another payment is made 200 kilometers away with a debit card belonging to the same person. Using Big Data allows ING to contact the customer to find out if this constitutes fraud, and if subsequent measures (such as blocking the debit card) are necessary. Not so long ago, these kind of improvements in customer service were not possible.
Customer privacy is our number one priority
The use of Big Data provides many opportunities, but also calls for caution. We fully recognise that privacy is a very sensitive issue, and ING’s number one priority is the protection of our customers’ personal information. ING will therefore never give personal information to third parties that is traceable to the individual. Customers can rest assured that ING will only use their personal information if it is permitted to do so. We will always act in accordance with rules and regulations, as well as our own business principles.
Improvement of customer service is key in applying Big Data
In using Big Data, ING has formulated the following goals:
1. Improving customer service
2. Countering fraud and cybercrime
3. Operational excellence
4. Diminishing risks (e.g. reducing payment arrears)
5. Creating commercial opportunities.
Pilot with customer service improvements
ING is exploring new opportunities for each of the above goals. In doing so, improving the quality of our customer service is the key priority. On 10 March 2014, an article in a leading Dutch newspaper specifically addressed a pilot project that ING plans to launch this year with a limited number of customers. As part of the recently launched 'Financially Fit' (Dutch only) campaign, ING is looking at ways to provide customers with extra financial advantages (e.g., discounts). For this pilot, ING is investigating whether customers would be interested in receiving relevant and tailored advertisements from third parties that are aligned with their spending pattern. Naturally, ING will adhere to all privacy conditions and requirements. In addition, the pilot is on an opt-in basis, which means that customers have to explicitly give their permission before their payment details can be analysed. If a customer in question no longer wishes to participate in the pilot, they can terminate their participation at any time.
ING emphasises that it will always operate with the customer’s best interests at heart in using Big Data. The focus lies on improving customer satisfaction and safeguarding customer privacy. At all times, customers have to feel that ING can be trusted with their personal information.
The pilot project led to many queries and comments from customers and other stakeholders, and caused debate about the use of customer data. ING Netherlands CEO Nick Jue addressed the issue in a letter to customers, published on 17 March 2014. In the letter, Jue took responsibility for not communicating more clearly about this sensitive subject. The reactions have made clear that there are many questions and concerns about the protection of customer data. Jue apologized for the lack of clarity and the unrest caused.
Jue reiterated that ING will neither sell individual customer and transaction data to third parties, nor share the data with them. Protection of customer data is of the highest priority to ING and ING will adhere to applicable laws and regulations, codes of conduct and the ING Business Principles. In the envisaged pilot project, only customers who had actively applied to take part would participate and they would thereafter be able to terminate their participation at any time.
Of course ING listens carefully to all signals, Jue continued. ING will actively discuss the project with customers, regulators, and consumer and privacy organisations. Whether ING will go ahead with the pilot project, and if so, when and under what conditions will, only be determined after these discussions. The interests and preferences of customers will be central, Jue concluded.